Long Term Care

Transamerica remains one of the few companies that continues to sell standalone long term care (LTC) insurance in the U.S.  We fully support the work of the NAIC’s EX LTC Task Force, which is charged with developing (among other things) a harmonized process and actuarial methodology for the assessment of LTC rate increase requests.  Transamerica is actively engaged in advocacy efforts to support the prompt harmonization of LTC rate increase processes and methodologies.

Genetic Testing

Academic literature and consumer advocates have begun to criticize the use of genetic test results in underwriting life, disability and long term care policies.  Florida has now restricted the use of genetic testing results in underwriting to those situations where a physician-ordered genetic test is related to a diagnosis in the medical record.  Other states are analyzing similar approaches. Transamerica supports the long-recognized principle that the insurer and applicant should have access to the same information about the applicant’s health, and has actively opposed legislation that will restrict insurers’ ability to consider genetic testing primarily because it will lead to adverse selection (i.e., where the insured knows about a potential or actual health issue that the insurer does not know, and chooses to apply for life insurance and/or to seek higher coverage level based on his/her knowledge).

Supplemental Health

Transamerica sells a number of supplemental health insurance products, which are designed to provide a cash indemnity benefit if the policyholder satisfies the triggers for coverage.  Depending on the type of policy purchase, these triggers might be satisfied when the insured is hospitalized or is diagnosed with a specific disease such as cancer.  Transamerica supports the inclusion of supplemental health policy in employer cafeteria plans. 

Policy Illustrations

Transamerica supports policy illustration rules that help consumers determine the policy that is best suited for their needs.  To this end, we support illustration rules that help consumers understand the mechanics of a policy, as well as the risk and reward trade-offs of a policy being considered for purchase.         
Transamerica also supports illustration rules that promote a level competitive playing field.  No product or product feature should be unfairly advantaged or disadvantaged simply by virtue of the illustration rules.    
Finally, Transamerica supports applying the same illustration rules to both new sales as well as inforce contracts.  In this way, consumers get consistent information regardless of whether they are considering a new policy or reviewing the performance of an existing policy.     

RILAs and Other Innovative Products
Transamerica supports efforts to create regulatory frameworks that allow for product innovation.  New products should not be prohibited or disadvantaged because they do not fit within existing regulatory boxes.  A current example is Registered Indexed-Linked Annuities (RILAs), which are a hybrid between variable and fixed indexed annuities. For RILAs and other innovative products, Transamerica supports regulation that provides flexibility in product design, efficiency in bringing products to market, and robust and fair protection of consumers. 

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